CODE OF BUSINESS CONDUCT & ETHICS
Governance.
Purpose of this code.
Our Code of Business Conduct and Ethics (“Code”) is intended to document the principles of conduct and ethics to be followed by employees, officers and directors of Horizon Bioadvisory Ltd. ( “ Horizon” or “Company”).
Its purpose is to:
Promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
Promote avoidance of conflicts of interest, including disclosure to an appropriate person of any material transaction or relationship that reasonably could be expected to give rise to such a conflict;
This Code outlines a framework of guiding principles. As with any statement of policy, the exercise of judgment is required in determining the applicability of this Code to each individual situation.
It is the responsibility of every Horizon employee, officer and director never to engage in behaviour that harms the business or reputation of Horizon.
Responsibility.
Each employee, officer, contractor and director must at all times comply fully with applicable laws and regulations effecting its business and should avoid any situation that could be perceived as improper, unethical, or indicate a casual attitude towards compliance with the law, and / or commit or condone an illegal act or instruct another employee to do so.
No employee, officer, contractor, or director shall create or condone the creation of a false record and/or destroy or condone the destruction of a record, except in accordance with Company policies.
Compliance with Laws and Regulations.
Use of Agents and Non-Employees, Officers and Directors
Agents or other non-employees cannot be used to circumvent the law. Employees, officers and directors will not retain agents or other representatives to engage in practices that run contrary to this Code.
The Company's directors, officers, employees, and contractors owe a duty to the Company to advance the Company's legitimate interests to the best of their abilities. Directors, officers, contractors, and employees whether acting individually, jointly or in concert, or through affiliates, are prohibited from:
Corporate Opportunities.
taking business opportunities that are properly within the scope of the Company's activities using corporate property, information or position for personal gain; and
competing with the Company.
Employees, contractors, officers and directors of the Company shall attempt to avoid situations where their personal interest could conflict with the interests of the Company. Where conflicts arise, the individual will inform the Board of Directors.
Conflicts of interest arise where an individual's position or responsibilities with the Company present an opportunity for personal gain apart from the normal rewards of employment, to the detriment of the Company.
Conflicts of Interest.
Employees, officers, contractors and directors should endeavour to deal fairly with the Company’s partners, prospects, clients, service providers, suppliers, and employees. No employee, officer or director should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any unfair dealing practice.
Fair Dealing.
In addition to the general restrictions regarding material non-public information, each director, officer, and contractors or employee of Horizon should observe the confidentiality of information that they acquire by virtue of their relationship with Horizon.
Handling of Confidential Information.
Dealing with Suppliers.
The Company is a customer for suppliers of goods, services and facilities. Suppliers must understand that purchases by the Company will be made on the basis of price, quality, service, and suitability to the Company's needs.
Purchases of goods and services by the Company must not lead to employees, officers or directors, or their families, receiving any type of personal kickbacks or rebates.
‘Kickbacks’ and Rebates
Employees, officers, contractors and directors who make contact with public officials have a special responsibilities for upholding the Company's good name.
All representatives, agents and distributors acting on behalf of Horizon must comply with the anti-bribery, accounting and record keeping provisions in applicable jurisdictions.
Dealing with Public Officials.
The Company will comply with local laws as they relate to discrimination against any employee or applicant because of race, religion, colour, sex, sexual orientation, age, national or ethnic origin, or physical handicap (unless demands of the position are prohibitive).
All employees, officers and directors will be treated with equality during their employment without regard to their race, religion, colour, sex, sexual orientation, age, national or ethnic origin, or physical handicap, in all matters, including employment, upgrading, promotion, transfer, layoff, termination, rates of pay, selection for training and recruitment.
Equal Opportunity.
Health, Safety and Environmental Protection.
It is the Company's policy to pay due regard to the health and safety of its employees, officers, contractors and directors and others, to the state of the environment and to comply with workplace safety and environmental laws.
Should you be faced with an environmental health issue or have a concern about workplace safety, you should contact a company director.
Employees, officers, contractors, and directors engaged in international operations have a special responsibility to know and obey the laws and regulations of countries where they act for the Company. Customs vary throughout the world, but all employees, officers and directors must uphold the integrity of the Company in other nations diligently.
International Opperations.
Horizon Bioadvisory is committing to collecting, using and dealing with your personal information in accordance with UK protection law.
We must have a “lawful basis” for collecting and using your personal information. You will find list of possible bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
· Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
· Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
To receive our Customer Privacy Notice in full or to make a data protection rights request, please contact r.crebbin@horizonbioadvisory.com
Privacy Policy
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